Tax alert

Over the last decade many Israeli residents have sought to settle previously unreported accounts of foreign - held assets and the income generated by them with the Tax Authority. This was typically performed by a formal petition to the Tax Authority via the Voluntary Disclosure Procedure. The procedure has changed over the years, has been extended periodically, and even allowed for submission of anonymous requests and negotiations until an arrangement was reached.

The Tax Authority has just published a tax ruling (decision 4429/19), about VAT obligations for services rendered to a foreign resident via operation and management of a website advertising products of foreign suppliers abroad that provides links (affiliation) to the supplier websites abroad for purchase. The taxation decision states that full VAT applies to income from these services despite the rule that a zero rate VAT applies to services provided to foreign residents.

Over the last decade many Israeli residents have sought to settle previously unreported accounts of foreign-held assets and the income generated by them with the Tax Authority. This was typically performed by a formal petition to the Tax Authority via the Voluntary Disclosure Procedure. The procedure has changed over the years, has been extended periodically, and even allowed for submission of anonymous requests and negotiations until an arrangement was reached.

n April 2018 a (unanimous) ruling was handed down by the Supreme Court on two different appeals, which deal, inter alia, with the application of the section that deals with transfer pricing, in respect

ecently (in May 2019), a judgment was handed down, which the crypto industry had been anticipating (but not the result that was determined in it), pursuant to which a Bitcoin is deemed to be "an asset" and not "a currency".

The chapter on trusts in the Israeli Tax Ordinance affords the status of a taxpayer for tax purposes to a trust (including a registration number, a managed file in an assessing office etcetera), even though the trust itself is not an independent legal entity but is rather a legal arrangement, generally between a settlor and a trustee.

A few weeks ago, the Tax Authority published a new form, the title of which is "Annual report for a foreign resident company that has an exempt capital gain from the sale of securities that are traded on a Stock Exchange in Israel". Amazingly, the form was removed one day later and as of the

In March 2019, the final report by the Security Authority – The Committee for the Arrangement of the Issuance of Distributed Ledger Technology Based Crypto-currencies to the public. The final report was published after the publishing of a very detailed interim report, which was presented to the public in March 2018. The Committee's main role was to consider the application of the Securities Law to the issuance of crypto-currencies.

A tax ruling has been published recently, which deals with the taxation of income from the exercise of options by a returning resident. "Spoiler" – the Tax Authority has determined that income from options that have vested outside of Israel when the individual was a foreign resident is taxable in Israel, and thus it has retracted its position in previous tax rulings. This tax ruling